IN THE SUPERIOR COURT OF COBB COUNTY
STATE OF GEORGIA

Marquitta L. Portman,                  *
     Plaintiff,                        *
   v.                                  *
The Honorable GEORGE H. KREEGER,       *
The Hon. ROBERT E. FLOURNOY, Jr.       *
The Honorable DOROTHY ROBINSON,        *    CIVIL ACTION
The Honorable S. LARK INGRAM,          *    FILE NO.
The Honorable JAMES G. BODIFORD,       *
The Honorable MICHAEL STODDARD,        *    99-1-7941-24
JAY STEPHENSON, Clerk of Cobb County   *
    Superior Court,                    *
LARRY W. YARBROUGH, Attorney at Law,   *
DARYL KIDD, Attorney at Law,           *
GREGORY RUSSELL PORTMAN, and           *
R. WYNETTE KENNEDY PORTMAN,            *
    Defendants     

AFFIDAVIT OF MARQUITTA L. PORTMAN IN SUPPORT OF
MOTION TO DISQUALIFY
THE HONORABLE KENNETH NIX

COMES NOW , Marquitta L. Portman, Plaintiff in the above styled matter, and files this her Affidavit in Support of Motion to Disqualify the Honorable Kenneth Nix, and shows this Court the following:

1.

I am a citizen of the United States, and am competent to submit this affidavit based on my own personal knowledge.

2.

I am the Plaintiff in this action, Civil Action File NO. 99-1-7941-24 and I was the Plaintiff in Civil Action File No. 94-1-5243-22 and Civil Action File No. 96-1-2243-22. I was the Defendant in Civil Action File No. 96-1-0373-24

3.

I was notified in June of this year, 1999, that the underlying case, Civil Action File No. 94-1-5243-22, had been assigned, upon the voluntary recusal of the Honorable Conley Ingram, to a judge outside the Cobb Judicial Circuit, being the Honorable Jere F. White, senior judge from Bartow County.

4.

Such assignment of the Honorable Jere F. White to the underlying case was a clear statement that for any current Cobb County Superior Court Judge to act as trier would have the appearance of prejudice and bias.

Further, Affiant sayeth not.

Respectfully submitted, this 18th day of October 1999.
 
 
 

Marquitta L. Portman, Plaintiff

261 Pioneer Trail
Marietta, GA 30068-3470
770-971-9455 home
770-528-6627 ext. 233 school

Sworn to and subscribed before me this 18th day of October 1999.
 
 
 

Notary Public

Commission expires:

Note: This Affidavit was amended March 14, 2000